What is FBDE?
An FBDE (full-benefit dual eligible) is someone who qualifies for full Medicaid benefits through their state and is also enrolled in Medicare Part D. The excerpts cover two paths to meeting the Medicaid side of this definition.
What the rule says
“(b) Definitions—Full-benefit dual-eligible individual. For purposes of this section, a full-benefit dual eligible individual means an individual who is—”
“(1) Determined eligible by the State for—”
Case 1 — Full Medicaid benefits under the state plan or an 1115 demonstration:
“(i) Medical assistance for full-benefits under Title XIX of the Act for the month under any eligibility category covered under the State plan or comprehensive benefits under a demonstration under section 1115 of the Act; or”
Case 2 — Medically needy or more restrictive state eligibility criteria:
“(ii) Medical assistance under section 1902(a)(10(C) of the Act (medically needy) or section 1902(f) of the Act (States that use more restrictive eligibility criteria than are used by the SSI program) for any month if the individual was eligible for medical assistance in any part of the month.”
Both cases also require Part D eligibility:
“(2) Eligible for Part D in accordance with § 423.30(a) of this subpart.”
This definition also feeds into the broader "low-income subsidy eligible individual" category, which includes full-benefit dual eligibles as defined here.
To determine which case applies to a specific client, the deciding facts are: (1) which type of state Medicaid eligibility category the individual qualifies under (standard full-benefit category/1115 demonstration versus medically needy or a state's more restrictive SSI-related criteria), and (2) whether the individual meets Part D eligibility requirements under § 423.30(a).
Carrier and FMO rules are often stricter than CMS rules. This tool reports what CMS sources say and is not legal advice. Enrollment guidance shown is the CY 2027 version. Regulation text reflects the CY 2027 marketing rules, which apply to marketing beginning October 1, 2026.
This answer was generated by mapdbot from the sources listed below on September 23, 2026 and checked against them. Regulation text: eCFR as of 09/15/2026. It is for licensed insurance agents, is not legal advice, and does not cover carrier or FMO rules.